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Advanced '_ <br /> GeoEnvironmental, Inc . <br /> 16 October 2007 <br /> AGE-NC Project No. 96-0232 <br /> to 1g, <br /> Mr.Mike Infurna <br /> SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DEPARTMENT <br /> 600 East Main Street <br /> Stockton, CA 95202 <br /> Subject: Proposal for Alternative Method to Decommission CMT Wells <br /> FLAG CITY CHEVRON <br /> 6421 Capitol Avenue,Lodi, California <br /> Dear Mr. Infurna: <br /> In accordance with a San Joaquin County Environmental Health Department (SJCEHD) directive <br /> letter dated 21 September 2007,Advanced GeoEnvironmental, hie. (AGE) is proposing to utilize <br /> down-hole explosive charges as an alternative method to decommission a total of six(6)CMT wells <br /> at Flag City Chevron, 6421 Capitol Avenue, Lodi, California(site). <br /> In a letter dated 13 September 2007, AGE requested a variance from the SJCEHD by allowing <br /> abandonment of the above referenced CMT wells utilizing a Geoprobe®drive point to essentially <br /> hollow-out (remove) the "honeycomb" CMT inner chambers followed by pressure grouting. <br /> Additionally,as a backup measure,AGE proposed to decommission the CMT wells utilizing hollow <br /> stem auger over-drill techniques. However, in a letter dated 21 September 2007, the SJCEHD <br /> rejected AGE's backup proposal to utilize hollow stem auger over-drilling techniques,and directed <br /> that an alternative decommissioning method be presented for SJCEHD-approval. <br /> As a result,AGE contacted Mr.Robert Guardino of Water Well Technology Inc. (W WT) to discuss <br /> the possibility of decommissioning CMT wells utilizing explosives.W WT indicated that the above- <br /> referenced CMT wells could effectively be decommissioned by inserting a 50-grain detonating cord <br /> (i.e.prima-cord)inside the entire middle chamber of the CMT well, and by backfilling each outer- <br /> chamber of the CMT well with either a neat cement or(preferably) quick grout. Following proper <br /> placement of the prima-cord and neat cement or grout, detonation would occur, effectively <br /> "exploding outward"the well casing and neat cement into the native formation.Additional literature <br /> for the proposed detonating cord and well destruction procedures utilizing explosives is attached <br /> with this letter. <br /> Based on discussions with W WT,AGE is proposing to utilize explosives as an alternate CMT well <br /> decommissioning method. If this backup measure is approved by the SJCEHD,AGE will submit a <br /> S37 Shrew Road,Stockton,California 95215 <br /> 'fcicphonc(209)467-100 Fax(209)467-1118 <br />